Text

License Amendment Request for Technical Specification 3.6.3, Containment Isolation Valves, and Technical Specification 3.3.6, Containment Purge and Exhaust Isolation Instrumentation
	ML062200466
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/31/2006
From:	Gordon Peterson; Duke Energy Carolinas, Duke Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML062200466 (57)
	v • d • e

GARY R. PETERSON Duke Vice President Energyo McGuire Nuclear Station Duke Energy Corporation MGO1VP / 12700 Hagers Ferry Rd.

Huntersville, NC 28078 704 875 5333 704 875 4809 fax grpeters@duke-energy. corn July 31, 2006 U. S. Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, D.C. 20555

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 License Amendment Request for Technical Specification 3.6.3, Containment Isolation Valves, and Technical Specification 3.3.6, Containment Purge and Exhaust Isolation Instrumentation Pursuant to 10 CFR 50.90, Duke Energy Carolinas (Duke) is requesting an amendment to the McGuire Nuclear Station Facility Operating Licenses and Technical Specifications (TS).

This amendment request will revise TS 3.6.3, Containment Isolation Valves, and its associated Bases, by removing the allowance to open the upper containment purge isolation valves in the applicable modes consistent with the lower containment purge isolation valves.

Maintaining the upper containment purge isolation valves in the closed position is currently administratively controlled in Modes 1 through 4 at McGuire Nuclear Station.

These valves have a history of not fully seating closed after cycling without manual assistance.

Since there are no plans to upgrade these valves by modification, it is proposed to revise TS 3.6.3 and its Bases accordingly.

Catawba Nuclear Station TS 3.6.3 also does not allow opening the containment purge valves in Modes 1 through 4.

In addition, this amendment request will delete TS 3.3.6, Containment Purge and Exhaust Isolation Instrumentation, and its associated Bases.

The revision to TS 3.6.3 described above will maintain the containment purge isolation valves in the sealed closed position in the modes of applicability.

Therefore, there is no basis for a TS requirement to test their automatic containment isolation function.

A similar change was submitted and approved for Catawba Nuclear Station by Amendment Nos. 196/189 dated March 20, 2002.

www.duke-energy cor

U.S. Nuclear Regulatory Commission Page 2 July 31, 2006 The contents of this License Amendment Request (LAR) are as follows: provides a marked copy of the affected Technical Specification and Bases showing the proposed changes. provides reprinted pages of the affected Technical Specification and Bases with the proposed changes incorporated. provides a description of the proposed changes and the technical justification., pursuant to 10 CFR 50.92, provides the determination that this LAR contains No Significant Hazards Consideration., pursuant to 10 CFR 51.22, provides the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement.

Implementation of this proposed amendment to the McGuire Technical Specifications will impact the McGuire Updated Final Safety Analysis Report (UFSAR).

Section 6.2.4.4, Table 7-20, Table 9-39, Table 9-40, and Section 9.4.5 will be revised in accordance with 10 CFR 50.71(e).

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, this LAR has been reviewed and approved by the McGuire Plant Operations Review Committee and the Duke Corporate Nuclear Safety Review Board.

Pursuant to 10 CFR 50.91, a copy of this LAR is being forwarded to the appropriate North Carolina State officials.

Duke is requesting NRC review and approval of this LAR by July 31, 2007.

Also, the NRC's standard 30 day implementation grace period will be adequate for this LAR.

U.S. Nuclear Regulatory Commission Page 3 July 31, 2006 Inquiries on this matter should be directed to Lee A. Hentz at 704-875-4187.

Sincerely, Gary R.

Peterson Attachments

U.S. Nuclear Regulatory Commission Page 4 July 31, 2006 cc:

w/attachments W. D. Travers Regional Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85 Atlanta, GA 30303 J.

F. Stang, Jr.

Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop 8-H4A Washington, D.C.

20555 J.

B. Brady NRC Senior Resident Inspector McGuire Nuclear Station B.

0. Hall Section Chief Division of Radiation Section 1645 Mail Service Center Raleigh, NC 27699

U.S. Nuclear Regulatory Commission Page 5 July 31, 2006 OATH AND AFFIRMATION Gary R. Peterson affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

.aQW4ý Gary R. Peterson, Site Vice President Subscribed and sworn to me:

&2JU 8/, cWO4' Date Notary Public My commission expires:

L/* $7

/7, -R64(o J

Date

bxc:

w/attachments C.

J.

Thomas (MGO1RC)

R.

D. Hart (CN01RC)

B.

G.

Davenport (ON03RC)

R.

L. Gill, Jr (EC050)

J.

W. Knost (MG05SE)

ELL (EC050)

McGuire Master File # 1.3.2.9 NSRB Support Staff (EC05N)

ATTACHMENT 1 MARKED PAGES OF AFFECTED TECHNICAL SPECIFICATION

TABLE OF CONTENTS 1.0 USE AND APPLICATION..............................................................................

1.1-1 1.1 Definitions..............................................................................................

1.1-1 1.2 Logical Connectors................................................................................

1.2-1 1.3 Completion Times..................................................................................

1.3-1 1.4 Frequency..............................................................................................

1.4-1 2.0 SAFETY LIMITS (SLs)..................................................................................

2.0-1 2.1 S Ls........................................................................................................

2.0-1 2.2 SL Violations..........................................................................................

2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY.............. 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY.............................

3.0-4 3.1 REACTIVITY CONTROL SYSTEMS.....................................................

3.1.1-1 3.1.1 SHUTDOWN MARGIN (SDM)........................................................

3.1.1-1 3.1.2 Core Reactivity...............................................................................

3.1.2-1 3.1.3 Moderator Temperature Coefficient (MTC).....................................

3.1.3-1 3.1.4 Rod Group Alignment Limits..........................................................

3.1.4-1 3.1.5 Shutdown Bank Insertion Limits.....................................................

3.1.5-1 3.1.6 Control Bank Insertion Limits.........................................................

3.1.6-1 3.1.7 Rod Position Indication..................................................................

3.1.7-1 3.1.8 PHYSICS TESTS Exceptions........................................................

3.1.8-1 3.2 POWER DISTRIBUTION LIMITS...........................................................

3.2.1-1 3.2.1 Heat Flux Hot Channel Factor (Fo(X,Y,Z))......................................

3.2.1-1 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (FeH(X,Y))................... 3.2.2-1 3.2.3 AXIAL FLUX DIFFERENCE (AFD).................................................

3.2.3-1 3.2.4 QUADRANT POWER TILT RATIO (QPTR)...................................

3.2.4-1 3.3 INSTRUMENTATION............................................................................

3.3.1-1 3.3.1 Reactor Trip System (RTS) Instrumentation...................................

3.3.1-1 3.3.2 Engineered Safety Feature Actuation System (ESFAS)

Instrumentation........................................................................

3.3.2-1 3.3.3 Post Accident Monitoring (PAM) Instrumentation...........................

3.3.3-1 3.3.4 Remote Shutdown System.............................................................

3.3.4-1 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation........................................................................

3.3.5-1 3.3.6 nt-arnm t P "ge d

austAola n

S str

e.

6-1 3.4 REACTOR COOLANT SYSTEM (RCS).................................................

3.4.1-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits..................................................

3.4.1-1 3.4.2 RCS Minimum Temperature for Criticality......................................

3.4.2-1 3.4.3 RCS Pressure and Temperature (P/T) Limits.................................

3.4.3-1 3.4.4 RCS Loops-MODES 1 and 2.......................................................

3.4.4-1 3.4.5 RCS Loops-MODE 3...................................................................

3.4.5-1 McGuire Units 1 and 2 i

Amendment Nos.

(ýnmqp(P/ge ap6 Exh/ust/so I a;4n-I dtrurp&tT/býn

, c ýon t x12 3.3.6 3.3 INSTRUMENTATION 3.3.6 Co in ent rge nd xha t Is tio In umvfita n

McGuire Units 1 and 2 3.3.6-1 Amendment Nos.

4/1

S V\\EILLANCE REQUIREMENTS Containment Purge and Exhaust Isolation Instrumentatio 3 6 P-JLJy I r------------------

Refer to able 3.3.6-1 to determine which SRs apply for each Containment P geand Exhaust Isolation ction.

SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CTUATION LOGIC TEST.

31 days on a STAGGERED TEST BASIS SR 3.3.6.2 Perform MASTER E

TEST.

31 days on a STAGGERED TEST BASIS SR 3.3.6.3 Perform S VE RELAY TEI.

92 days SR 3.3.6.4 18 NOTEmoh-s

..... cation of.s~etpoint is not requie

__*Perform TADOT.

18 months

.C.11

.i; b-e-

rot 9

e-McGuire Units 1 and 2 3.3.6-2 Amendment Nos. 184/166

Containment Purge and Exhaust Isolation In mentation J

3.3.6 Table 3.3.6-1 (page 1 of 1)

Containment Purge and Exhaust Isolation Instrumen~tation fo

1.

Manual Initiation

2.

Automatic Actuation Logic and Actuation Relays

3.

Safety Injection 7

SR 3.3.6.4 NA SR 3.3.6.1 NA SR 3.3.6.2 SR 3.3.6.3

, ESFAS Instrumentation," Function 1, for all initiation McGuire Units 1 and 2 3.3.6-3 Amendment Nos. 194/175

Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 APPLICABILITY:

Each containment isolation valve shall be OPERABLE.

MODES 1,2, 3, and 4.

ACTIONS

1.

Penetration flow path(s) except for c ntainmentt urge supply and/or exhaust isolation valves for the lower compartment an instrum t room may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

NOTE --------

A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two containment and de-activated automatic isolation valves, valve, closed manual valve, blind flange, or check valve inside One or more penetration containment with flow flow paths with one through the valve secured.

containment isolation valve inoperable except AND for purge valve or reactor building bypass leakage not within limit.

(continued)

McGuire Units 1 and 2 3.6.3-1 Amendment Nos. (ýý

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SURVEILýý FREQUENCY SR 3.6.3.1 Verify each containment purg alve for the lower 31 days compartme ndnstrumad e t room is sealed closed, excep orone purge valve in a enetration flow path iei Condition E of this LCO.

pe...-

o SR 3.6.3.2 SR 3.6.3.3

.------------ NOTE-------------

Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and blind flange that is located outside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

31 days (continued)

Amendment Nos.4 McGuire Units 1 and 2 3.6.3-5

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 1-SR 3.6.3.4 NOTE Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and blind flange that is located inside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days SR 3.6.3.5 Verify the isolation time of automatic power operated In accordance with containment isolation valve is within limits, the Inservice Testing Program In accordance with SR 3.6.3.6 Perform leakage rate testing for containment purge lower the Containment and upper compartment and Instrument room valves with Leakage Rate resilient seals.

Testing Program 6

e SR 3.6.3.7 Verify each automatic containment isolation valve that is 18 months not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

(continued)

McGuire Units 1 and 2 3.6.3-6 Amendment Nos. 0ýý

TABLE OF CONTENTS B 2.0 SAFETY LIMITS (SLs)

B 2.1.1 Reactor Core SLs...........................................................................

B 2.1.1-1 B 2.1.2 Reactor Coolant System (RCS) Pressure SL..................................

B 2.1.2-1 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY....... B 3.0-1 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY......................

B 3.0-9 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.1 SHUTDOWN MARGIN (SDM)........................................................

B 3.1.1-1 B 3.1.2 Core Reactivity................................................................................

B 3.1.2-1 B 3.1.3 Moderator Temperature Coefficient (MTC).....................................

B 3.1.3-1 B 3.1.4 Rod Group Alignment Limits...........................................................

B 3.1.4-1 B 3.1.5 Shutdown Bank Insertion Limits B 3.1.5-1 B 3.1.6 Control Bank Insertion Limits..........................................................

B 3.1.6-1 B 3.1.7 Rod Position Indication...................................................................

B 3.1.7-1 B 3.1.8 PHYSICS TESTS Exceptions.........................................................

B 3.1.8-1 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 Heat Flux Hot Channel Factor (FQ(X,Y,Z)).....................................

B 3.2.1-1 B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (FAH(X,Y))................... B 3.2.2-1 B 3.2.3 AXIAL FLUX DIFFERENCE (AFD).................................................

B 3.2.3-1 B 3.2.4 QUADRANT POWER TILT RATIO (QPTR)....................................

B 3.2.4-1 B 3.3 INSTRUMENTATION B 3.3.1 Reactor Trip System (RTS) Instrumentation...................................

B 3.3.1-1 B 3.3.2 Engineered Safety Feature Actuation System (ESFAS)

Instrum entation.......................................................................

B 3.3.2-1 B 3.3.3 Post Accident Monitoring (PAM) Instrumentation............................

B 3.3.3-1 B 3.3.4 Remote Shutdown System..............................................................

B 3.3.4-1 B 3.3.5 Loss of o

r P DiesI GeneratorD tart Instrumentation B 3.3.5-1 B 3.3.6 C. tain ent Prge andExhau Isolat* n Insjrumeitation........... B 3.3.6-1 B 3.4 REACTOR COOLANT SYSTEM (RCS) ec(

B 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits.................................................

B 3.4.1-1 B 3.4.2 RCS Minimum Temperature for Criticality.......................................

B 3.4.2-1 B 3.4.3 RCS Pressure and Temperature (P/T) Limits.................................

B 3.4.3-1 B 3.4.4 RCS Loops-MODES 1 and 2........................................................

B 3.4.4-1 B 3.4.5 RCS Loops-MODE 3....................................................................

B 3.4.5-1 B 3.4.6 RCS Loops-MODE 4....................................................................

B 3.4.6-1 B 3.4.7 RCS Loops-MODE 5, Loops Filled.......................................... '.... B 3.4.7-1 B 3.4.8 RCS Loops-MODE 5, Loops Not Filled.........................................

B 3.4.8-1 B 3.4.9 Pressurizer......................................................................................

B 3.4.9-1 B 3.4.10 Pressurizer Safety Valves...............................................................

B 3.4.10-1 B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)......................

B 3.4.11-1 B 3.4.12 Low Temperature Overpressure Protection (LTOP) System........... B 3.4.12-1 B 3.4.13 RCS Operational LEAKAGE...........................................................

B 3.4.13-1 McGuire Units 1 and 2 i

Revision Noo '

Ctiýnýt/urge,-,nd Fau syolatidn IrA~rumita -

B 3.3.6 B 3.3 INSTRUMENTATION 3.3.6 Cýý-tntme_,Kt P~uFe a~nEx~hast ýIs/latio*'nstlg*mqK~a 7 4n*e BACK OND Cotainme purge and exha isolation i trumentto loe the Scontainment isolation valve/,in the Con nment Purg has Syste.

J J

Thi

'ction isolates the.. ntainme~nt mosphere fror the environm/e t tol

\\~~~ /

imize releases of r~ioactivitY,ithe event of n accident. Th esystem

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may be in use dur reactor oration and.*. the reactor s wn".

ContJnme urg and austisolti iitiaes o

m ratic safety l

"ctnje on sinalth ghth Cnt mntIslaio hase A Funti orby a

a acuaion has A sol *.

he Bases for."

L;K-2,"En*ee ae etr cutiSse (ESFAS),/"

//

J stru mentati

" discuss

,t/

modes of ti~n "

J" SEach oJf e purge syst rfs has inner a* outer containm 1iolation co.

anetprioain, coebohinadutesr.

ntaimen isatin vlve.

ee sstes a

scibe inthe Base's

/J for LCO 3.,",Containme solation Valves

//

APPLIOA*

Th safety analys assume that the ontainment rema' intact with SAFET ANALYSES,*netrations un cessary for cor ooling isolated e fry in the event,

/

within appro *~I ately 60 secon

. The isolation o te purge valvesh

/

not been/a alyzed mechani cally in the dose_ alculations, althou its rapid is ation is assumne.Containment is tion in turn ensur meetingmet thei nt ai~nmt eSaskamrate ntsaunptin of thensinfett an ajyses, and/

e ursta h

ao*ae ciet ite radiological ses are bel*v

/

0 ~CFa 100 (Re1) limits.

/

providn afiltered releasell within limits.

._/

/riterion 3 of 10 FR 50.36 (Ref.

/

McGuire Units 1 and 2 B 3.3.6-1 Revision No./O

BASES Containment Purge and Exhaust Isolation Instrumentatio'1 7.6 LCO P

C The LCO requirements ensure that the instrumentation necessfry to initiate Containment Purge and Exhaust Isolation, listed in Table 3.3.6-1, is OPERABLE.

/

1.

Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate Containment Purge Isolation at arnytime by using either of o switches (manual Phase A actuatis,( or manual spray a tuation) in the control room. Either,,7witch actuates its associated tra. This action will cause actuatin of all components in the sam manner as any of the automatic actuation signals.

\\

/

The L* for Manual lnitiatione/nsures the proper amount of redundan is maintained i the manual actuation circuitry to ensure the erator hasjanual initiation capability.

Each channel c nsist of one push button and the interconnecting wiring to the actu tio logic cabinet.

2.

Automatic Acttution L 1ic and Actuation Relays

/\\

The LCO rq4uires two traihs of Automatic Actuation Logic and Actuation/Relays OPERABL' to ensure that no single random failure n prevent automatic hýuation.

Aut atic Actuation Logic and Ac'tuation Relays consist of the sa ne features and operate in the s e manner as described for ESFAS Function 1.b, SI, and ESFAS Function 3.a, Containment

/'Phase A Isolation. The applicable MO6ES and specified conditions for the containment purge isolation portion of these Functions are different and less restrictive than those for their Phase A isolation and SI roles. If one or moreof the SI or Phase A isolation Functions becomes inoperable in sucha manner that only the Containment Purge Isolation Function is affected, the Conditions applicable to their SI and Phase A isolatiopn Functions need not be entered. The less restrictive Actions specified for inoperability of the Containment Purge Isolation Functioins specify sufficient compensatory measures for this case.

/

,/"\\

3.

Safety Iniection Refer to LCO 3.3.2, Function 1, for all initiating Functions and requirements.

McGuire Units 1 and 2 B 3.3.6-2 Revision No. 0

BAS\\ES Containment Purge and Exhaust Isolation Instrumentation B 37 APPLICABILI The Manual Initiation, Automatic Actuation Logic and Actuation R ays, and Safety Injection Functions are required OPERABLE in MOES 1,2, 3, and 4. Under these conditions, the potential exists for an cident that could release fission product radioactivity into containmen Therefore, e containment purge and exhaust isolation instrument on must be

-Delete-0 RABLE in these MODES.

l I.,

While* MODES 5 and 6 without fuel handling in j~ogress, the

<., -.,r

contain nt purge and exhaust isolation instru entation need not be

~

OPERAB LE since the potential for radioactive/releases is minimized and

.. 5e..

operator act n is sufficient to ensure post

/cident offsite doses are maintained wi in the limits of Reference During fuel handlih operations w iti c nanm ent, the purge system must be exhausting l~rough OPEP BLE filters as required by LCO 3.9.4, S"Containment Penetr'ons"i ACTIC)NS A Note has been added to e ACTIONS to clarify the application of Completion Time rules., he onditions of this Specification may be entered independently or each unction listed in Table 3.3.6-1. The Completion Time(s) f the inope ble channel(s)/train(s) of a Function will be tracked separa ly for each Fu tion starting from the time the Condition wase ered for that Funct n.

A.1 Condi' n A applies to all Containment Purge d Exhaust Isolation Fun ions and addresses the train orientation o he Solid State Protection S

em (SSPS) and the master and slave relays r these Functions.

If a train is inoperable, operation may continue as Ion as the Required Action for the applicable Conditions of LCO 3.6.3 is me or each valve made inoperable by failure of isolation instrumentation.

McGuire Units 1 and 2 B 3.3.6-3 Revision No. 0

BASES\\\\

Containment Purge and Exhaust Isolation Instrumentation B 3.3.6

-P, 1, Fa ý SURVEILLA E

A Note has been added to the SR Table to clarify that Table 3.3.6-1/

REQUIREMEN determines which SRs apply to which Containment Purge and E aust Isolation Functions.

3.3.6.1 SR..6.1 is the performance of an ACTUATIO-N L IC TEST. The train b *ng tested is placed in the bypass conditio, thus preventing inadvert t actuation. Through the semiautom ic tester, all possible logic com lations, with and without applicab ermissives, are tested for each pro ction function. In addition, th/master relay coil is pulse tete n,

aster reaycolissus tested for conty.This verifies that th ogic modules are OPERABLE and there is an tact voltage signal pa to the master relay coils. This test is performed very 31 days on a TAGGERED TEST BASIS. The Surveillance interv is acceptable ased on instrument reliability and industry operating ex erience.

SR 3.3.6.2 Q-SR 3.3.6.2 is the perfo ance f a MASTER RELAY TEST. The MASTER RELAY T T is the e ergizing of the master relay, verifying contact operation d a low volta continuity check of the slave relay coil. Upon mast relay contact op ation, a low voltage is injected to the slave relay coil This voltage is insu i ient to pick up the slave relay, but large enoug o demonstrate signal pa continuity. This test is performed very 31 days on a STAGGE D TEST BASIS. The Surveilla e interval is acceptable based oinstrument reliability and indust operating experience.

S 3.3.6.3 SR 3.3.6.3 is the performance of a SLAVE RELAY T

.The SLAVE RELAY TEST is the energizing of the slave relays. Con ct operation is verified in one of two ways. Actuation equipment that ma,be operated in te design mitigation mode is either allowed to function or i laced in a condition where the relay contact operation can be verified wi out operation of the equipment. Actuation equipment that may note

~~perated in the design mitigation mode is prevented from operatib by the SLAVE RELAY TEST circuit. For this latter case, contact operatioris verified by a continuity check of the circuit containing the slave relay.'

This test is performed every 92 days. The Frequency is acceptable based on instrument reliability and industry operating experience.

McGuire Units 1 and 2 B 3.3.6-4 Revision No. 0

Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 BASES SUR ILLANCE REQUIREMENTS (continued)

SR 3.3.6.4 SR 3.3.6.4 is the performance of a TADOT.

is test is a check of the ual Actuation Functions and is perfor d every 18 months. Each Man Actuation Function is tested u o, and including, the master relay coils. In me instances, the test i udes actuation of the end device (i.e., pump s s, valve cycles,

.).

The test also inclu trip vices that provide actuation signals directly to the SSPS, bassin e analog process control equipment. The SR is modified by a Note ex des verification of setpoints during the TADOT. The Fu tions teste ave no setpoints associated with them.

The Frequ cy is based on the know eliability of the Function and the oper 10 eFr5 echi REFERENCES 1.

10 CFR 100.1 1.

2.

10 CFR 50.36, Technical Specifications, (c)(2(i)

McGuire Units 1 and 2 B 3.3.6-5 Revision No. 0

Containment Isolation Valves B 3.6.3 BASES BACKGROUND (continued)

Containment Purcqe System The Containment Purge System operates to supply outside air into the containment for ventilation and cooling or heating and may also be used to reduce the concentration o within conta

~~~~~~and during personnel access.

There are five purge air supply line penetrations and four exhaust penetrations in the containment. The supply penetrations include one line through the reactor building wall, two through the containment vessel into upper containment, and two lines through the containment vessel into lower containment. The exhaust penetrations include two lines through the containment vessel out of upper containment, one-line through the containment vessel out of lower containment, and one line through the reactor building wall. Two normally closed isolation valves at each containment vessel penetration provide containment isolation.

The upp!,"containmei purge poi of the sWem has thepability tp' Sopee when p ds of sust ed persoel access a equired.Tis J5allowed f ormal ope ion (MOD 1 -4), prVd no mor an one air on uI ad e exhaust fMo ath) are. pen at on lime. The upper cioInmn sup an xhau t are poea e ring rluel*

eraid h (MO ES -6).,f he exhaust portin ps reduce the onsequences of a fuel handling accident in containment by removing and filtering any airborne radioactive effluents that may result from a fuel APPLICABLE The containment isolation valve LCO was derived from the SAFETY ANALYSES assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during major accidents. As part of the containment boundary, containment isolation valve OPERABILITY supports leak tightness of the containment. Therefore, the safety analyses of any event requiring isolation of containment is applicable to this LCO.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident (LOCA) and a rod ejection accident (Ref. 1). In the analyses for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This McGuire Units 1 and 2 B 3.6.3-2 Revision No C)

INSERT A TECH SPEC BASES 3.

6.3 BACKGROUND

SECTION This system is used during Mode 5, Mode 6, and No Mode and is not utilized during Modes 1 through 4.

The penetration valves are sealed closed in Modes 1 through 4.

Containment Isolation Valves B 3.6.3 BASES APPLICABLE SAFETY ANALYSES (continued) ensures that potential paths to the environment through containment isolation valves (including containment purge valves) are minimized. The safety analyses assume that the lower compartment and instrument room purge valves are closed at event initiation.

The DBA analysis assumes that, within 76 seconds after the accident, isolation of the containment is complete and leakage terminated except for the design leakage rate, U. The containment isolation total response time of 76 seconds includes signal delay, diesel generator startup (for loss of offsite power), and containment isolation valve stroke times.

The single failure criterion required to be imposed in the conduct of plant safety analyses was considered in the original design of the containment purge valves. Two valves in series on each purge line provide assurance that both the supply and exhaust lines could be isolated even if a single failure occurred The lower and instrument room purge valves may be unable to close in the environment following a LOCA. Therefore, each of the lower anctt, v

instrument room purge valves is required to remain sealed closed during e

.MODES 1,2, 3, and 4.

he up purge vave -may be opedfor

/

-/

R' nside ons. In

acase, the i e failure c rion remai a

I

-t-.

tie c n In u g sdu t f *u ei h e

3rcuit a oiated *each valv gain, the ge system ye desi The containment isolation valves satisfy Criterion 3 of 10 CFR 50.36 (Ref.

2).

LCO Containment isolation valves form a part of the containment boundary.

The containment isolation valves' safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA.

The automatic power operated isolation lves are required to have isolation times within limits and to act ate on an automatic isolation signal. The lower compartmen and instrument room purge valves must be maintained sealed closed. The valves covered by this LCO are listed along with their associated s oke times in the UFSAR (Ref. 3).

McGuire Units 1 and 2 B 3.6.3-3 Revision No$

INSERT B TECH SPEC BASES 3.6.3 APPLICABLE SAFETY ANALYSIS SECTION Although the upper containment purge isolation valves are capable of closing under accident conditions, their capability to fully seal without manual assistance has proven to be unreliable.

Therefore, these valves are required to be maintained sealed closed during Modes 1, 2, 3,

and 4.

Containment Isolation Valves B 3.6.3 BASES LCO (continued)

The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed systems are intact. These passive isolation valves/devices are those listed in Reference 3.

Purge valves with resilient seals and reactor building bypass valves must meet additional leakage rate requirements. The other containment isolation valve leakage rates are addressed by LCO 3.6.1, "Containment,"

as Type C testing.

This LCO provides assurance that the containment isolation valves and purge Valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents.

APPLICABILITY In MODES 1,2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.4, "Containment Penetrations."

ACTIONS The ACTIONS are modifiey a o e wing penetration flow paths, except for lgcontain'ent purge supply and exhaust valves for the lower compa -rment and instrument room, to be unisolated intermittently

,d-ner tdinisrative controls. These administrative controls consist of

./

stationing a dedicated operator at the valve controls, who is in continuous I*)

1f/PCIf~

C"

.....e.. )/ Jcommunication with the control room. In this way, the penetration can be rapidly isolated when a need for containment isolation is indicated. For valve controls located in the control room, an operator may monitor containment isolation signal status rather than be stationed at the valve controls. Due to the size of the containment purge line penetration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls. A single purge valve in a penetration flow path may be opened to effect repairs to an inoperable valve, as allowed by SR 3.6.3.1.

McGuire Units 1 and 2 B 3.6.3-4 Revision No,

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued)

Required Action C.2 is modified by a Note that applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small.

D.1 With the reactor building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Restoration can be accomplished by isolating the penetration(s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange: When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration(s) and the relative importance of secondary containment bypass leakage to the overall containment function.

E.1, E.2, and E.3 E,

P1C. :ve3 In the event one or more purge valves for upper and lower containment or instrument room in one or more penetration flow paths are not within the purge valve leakage limits, leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, or blind flange. A valve with resilient seals utilized to satisfy Required Action E.1 must have been demonstrated to meet the leakage requirements of SR 3.6.3.6. The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist.

In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is McGuire Units 1 and 2 B 3.6.3-8 Revision N ý?,

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation.

Rather, it involves verification, through a system walkdown or computer status indication, that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

For the containment purge valve with resilient seal that is isolated in accordance with Required Action E.1, SR 3.6.3.6 must be performed at least once every 92 days. This assures that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated.

F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE REQUIREMENTS SR 3.6.3.17 a* I--------

Each containment purge valve for the lower compartment an instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused b D inadvertent or spuriou openin of a coge vav t

a yi ns'v*

deoonszta-te t bi'-t-o e

ri n

o mt efsite ose*"h s ot be n r

es vaves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can McGuire Units 1 and 2 B 3.6.3-9 Revision NoM

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued) be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term "sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance permits opening one purge valve in a penetration flow path to perform repairs.

SR 3.6.3.2 This SR sure tat th ontai ent ge s ply and xhaust, iolati valve or th pper mpart nt ar ose s requi or, if pen, en for allo ble re on. If valvel ope n violati of thi R, t vye is nside iop able the i perable alve i ot ot rwise now o hay exces e lea ge w n close, it is n cons' ered to ha leak outsi f Ii, s. T S

qui to met w n Svalv are for t rea ns stat The Ives ay be ened for p sure c tol, RA air qu erati s for p sonn en

,or for urveil nces at req e the ves t e ope. The Ives wing I

hl g a LO A. T

refore, these Ives allo d to b pen f imit period of tim. The 31 (dnsai*day eeu snsse hor co) inmen solati valve This SR requires verification that each containment isolation manual valve and blind flange located outside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown or computer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative controls McGuire Units 1 and 2 B 3.6.3-10 Revision Noo

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)

OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses.

The isolation time is specified in the UFSAR and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient se

, additional leakage rate testing beyond the test requirements of 10 C 50, Appendix J, Option B is required to ensure OPERABILITY. The easured leakage rate for containment purge lower compartment and instrument room valves must be < 0.05 La when pressurized to Pa. The measured leakage rate for containment purge upper compartment valves must be <0.01 La when pressurized to P,. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), these valves will not be placed on the maximum extended test interval, but tested on the nominal test interval in accordance with the Containment Leakage Rate Testing Program.

SR 3.6.3.7 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

McGuire Units 1 and 2 B 3.6.3-12 Revision NO

ATTACHMENT 2 REPRINTED PAGES OF AFFECTED TECHNICAL SPECIFICATION

TABLE OF CONTENTS 1.0 USE AND APPLICATION...............................................................................

1.1-1 1.1 Definitions..............................................................................................

1.1-1 1.2 Logical Connectors.................................................................................

1.2-1 1.3 Completion Times...................................................................................

1.3-1 1.4 Frequency..............................................................................................

1.4-1 2.0 SAFETY LIMITS (SLs)...................................................................................

2.0-1 2.1 SLs.........................................................................................................

2.0-1 2.2 SL Violations..........................................................................................

2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY............... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY.............................. 3.0-4 3.1 REACTIVITY CONTROL SYSTEMS......................................................

3.1.1-1 3.1.1 SHUTDOW N MARGIN (SDM)........................................................

3.1.1-1 3.1.2 Core Reactivity...............................................................................

3.1.2-1 3.1.3 Moderator Temperature Coefficient (MTC)......................................

3.1.3-1 3.1.4 Rod Group Alignment Limits...........................................................

3.1.4-1 3.1.5 Shutdown Bank Insertion Limits......................................................

3.1.5-1 3.1.6 Control Bank Insertion Limits..........................................................

3.1.6-1 3.1.7 Rod Position Indication...................................................................

3.1.7-1 3.1.8 PHYSICS TESTS Exceptions.........................................................

3.1.8-1 3.2 POW ER DISTRIBUTION LIMITS............................................................

3.2.1-1 3.2.1 Heat Flux Hot Channel Factor (Fo(X,Y,Z))...................... :............... 3.2.1-1 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (FEH(X,Y))................... 3.2.2-1 3.2.3 AXIAL FLUX DIFFERENCE (AFD).................................................

3.2.3-1 3.2.4 QUADRANT POWER TILT RATIO (QPTR)....................................

3.2.4-1 3.3 INSTRUMENTATION.............................................................................

3.3.1-1 3.3.1 Reactor Trip System (RTS) Instrumentation....................................

3.3.1-1 3.3.2 Engineered Safety Feature Actuation System (ESFAS)

Instrumentation......................................................,.................. 3.3.2-1 3.3.3 Post Accident Monitoring (PAM) Instrumentation............................ 3.3.3-1 3.3.4 Remote Shutdown System..............................................................

3.3.4-1 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.........................................................................

3.3.5-1 3.3.6 Not Used.........................................................................................

3.3.6-1 3.4 REACTOR COOLANT SYSTEM (RCS)..................................................

3.4.1-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits...................................................

3.4.1-1 3.4.2 RCS Minimum Temperature for Criticality.......................................

3.4.2-1 3.4.3 RCS Pressure and Temperature (P/T) Limits..................................

3.4.3-1 3.4.4 RCS Loops-MODES 1 and 2........................................................

3.4.4-1 3.4.5 RCS Loops-MODE 3....................................................................

3.4.5-1 McGuire Units 1 and 2 i

Amendment Nos.

3.3.6 3.3 INSTRUMENTATION 3.3.6 Not Used McGuire Units 1 and 2 3.3.6-1 Amendment Nos.

Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 APPLICABILITY:

Each containment isolation valve shall be OPERABLE.

MODES 1, 2, 3, and 4.

ACTIONS I '

-j I

I--- ý,3 -

1.

Penetration flow path(s) except for containment purge supply and/or exhaust isolation valves for the lower compartment, upper compartment, and incore instrument room may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

NOTE----

A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path by penetration flow paths use of at least one closed with two containment and de-activated automatic isolation valves, valve, closed manual valve, blind flange, or check valve inside One or more penetration containment with flow flow paths with one through the valve secured.

containment isolation valve inoperable except AND for purge valve or reactor building bypass leakage not within limit.

(continued)

McGuire Units 1 and 2 3.6.3-1 Amendment Nos.

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each containment purge supply and exhaust valve 31 days for the lower compartment, upper compartment, and incore instrument room is sealed closed, except for one purge valve in a penetration flow path while in Condition E of this LCO.

SR 3.6.3.2 Not Used.

SR 3.6.3.3 NOTE--

Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and blind 31 days flange that is located outside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

I McGuire Units 1 and 2 3.6.3-5 Amendment Nos.

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4

-'l'*U r-Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and blind flange that is located inside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days SR 3.6.3.5 Verify the isolation time of automatic power operated In accordance with containment isolation valve is within limits, the Inservice Testing Program In accordance with SR 3.6.3.6 Perform leakage rate testing for containment purge lower the Containment and upper compartment and incore Instrument room Leakage Rate valves with resilient seals.

Testing Program SR 3.6.3.7 Verify each automatic containment isolation valve that is 18 months not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

I (continued)

McGuire Units 1 and 2 3.6.3-6 Amendment Nos.

TABLE OF CONTENTS B 2.0 SAFETY LIMITS (SLs)

B 2.1.1 Reactor Core SLs............................................................................

B 2.1.1-1 B 2.1.2 Reactor Coolant System (RCS) Pressure SL...................................

B 2.1.2-1 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY........ B 3.0-1 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY....................... B 3.0-9 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.1 SHUTDOWN MARGIN (SDM).........................................................

B 3.1.1-1 B 3.1.2 Core Reactivity................................................................................

B 3.1.2-1 B 3.1.3 Moderator Temperature Coefficient (MTC)......................................

B 3.1.3-1 B 3.1.4 Rod Group Alignment Limits............................................................

B 3.1.4-1 B 3.1.5 Shutdown Bank Insertion Limits.......................................................

B 3.1.5-1 B 3.1.6 Control Bank Insertion Limits................................ *.......................... B 3.1.6-1 B 3.1.7 Rod Position Indication....................................................................

B 3.1.7-1 B 3.1.8 PHYSICS TESTS Exceptions..........................................................

B 3.1.8-1 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 Heat Flux Hot Channel Factor (FQ(X,Y,Z))......................................

B 3.2.1-1 B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (FAH(X,Y))................... B 3.2.2-1 B 3.2.3 AXIAL FLUX DIFFERENCE (AFD)..................................................

B 3.2.3-1 B 3.2.4 QUADRANT POWER TILT RATIO (QPTR)....................................

B 3.2.4-1 B 3.3 INSTRUMENTATION B 3.3.1 Reactor Trip System (RTS) Instrumentation....................................

B 3.3.1-1 B 3.3.2 Engineered Safety Feature Actuation System (ESFAS)

Instrum entation........................................................................

B 3.3.2-1 B 3.3.3 Post Accident Monitoring (PAM) Instrumentation.............................

B 3.3.3-1 B 3.3.4 Remote Shutdown System..............................................................

B 3.3.4-1 B 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.B 3.3.5-1 B 3.3.6 Not Used.........................................................................................

B 3.3.6-1 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits..................................................

B 3.4.1-1 B 3.4.2 RCS Minimum Temperature for Criticality........................................

B 3.4.2-1 B 3.4.3 RCS Pressure and Temperature (PIT) Limits..................................

B 3.4.3-1 B 3.4.4 RCS Loops-MODES 1 and 2.........................................................

B 3.4.4-1 B 3.4.5 RCS Loops-MODE 3.....................................................................

B 3.4.5-1 B 3.4.6 RCS Loops-MODE 4.....................................................................

B 3.4.6-1 B 3.4.7 RCS Loops-MODE 5, Loops Filled................................................

B 3.4.7-1 B 3.4.8 RCS Loops-MODE 5, Loops Not Filled..........................................

B 3.4.8-1 B 3.4.9 Pressurizer......................................................................................

B 3.4.9-1 B 3.4.10 Pressurizer Safety Valves................................................................

B 3.4.10-1 B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)....................... B 3.4.11-1 B 3.4.12 Low Temperature Overpressure Protection (LTOP) System............ B 3.4.12-1 B 3.4.13 RCS Operational LEAKAGE............................................................

B 3.4.13-1 McGuire Units 1 and 2 i

Revision No.

I B 3.3.6 B 3.3 INSTRUMENTATION B 3.3.6 Not Used McGuire Units 1 and 2 B 3.3.6-1 Revision No.

Containment Isolation Valves B 3.6.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.3 Containment Isolation Valves BASES BACKGROUND The containment isolation valves form part of the containment pressure

boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. These isolation devices are either passive or active (automatic). Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are considered passive devices. Check valves, or other automatic valves designed to close without operator action following an accident, are considered active devices. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses. One of these barriers may be a closed system. These barriers (typically containment isolation valves) make up the Containment Isolation System.

Automatic isolation signals are produced during accident conditions.

Containment Phase "A" isolation occurs upon receipt of a safety injection signal. The Phase "A" isolation signal isolates nonessential process lines in order to minimize leakage of fission product radioactivity. Containment Phase "B" isolation occurs upon receipt of a containment pressure High-High signal and isolates the remaining process lines, except systems required for accident mitigation. In addition to the Phase "A" isolation signal, the purge and exhaust valves receive an isolation signal on a containment high radiation condition. As a result, the containment isolation valves (and blind flanges) help ensure that the containment atmosphere will be isolated from the environment in the event of a release of fission product radioactivity to the containment atmosphere as a result of a Design Basis Accident (DBA).

The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the time limits assumed in the safety analyses. Therefore, the OPERABILITY requirements provide assurance that the containment function assumed in the safety analyses will be maintained.

McGuire Units 1 and 2 B 3.6.3-1 Revision No.

Containment Isolation Valves B 3.6.3 BASES BACKGROUND (continued)

Containment Purge System The Containment Purge System operates to supply outside air into the containment for ventilation and cooling or heating and may also be used to reduce the concentration of airborne radioactivity within containment prior to and during personnel access. This system is used during Mode 5, Mode 6, and No Mode and is not utilized during Modes 1 through 4.

The penetration valves are sealed closed in Modes 1 through 4.

There are five purge air supply line penetrations and four exhaust penetrations in the containment. The supply penetrations include one line through the reactor building wall, two through the containment vessel into upper containment, and two lines through the containment vessel into lower containment. The exhaust penetrations include two lines through the containment vessel out of upper containment, one line through the containment vessel out of lower containment, and one line through the reactor building wall. Two normally closed isolation valves at each containment vessel penetration provide containment isolation.

The exhaust portion helps to reduce the consequences of a fuel handling accident in containment by removing and filtering any airborne radioactive effluents that may result from a fuel handling accident.

APPLICABLE The containment isolation valve LCO was derived from the SAFETY ANALYSES assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during major accidents. As part of the containment boundary, containment isolation valve OPERABILITY supports leak tightness of the containment. Therefore, the safety analyses of any event requiring isolation of containment is applicable to this LCO.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident (LOCA) and a rod ejection accident (Ref. 1). In the analyses for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This McGuire Units 1 and 2 B 3.6.3-2 Revision No.

Containment Isolation Valves B 3.6.3 BASES APPLICABLE SAFETY ANALYSES (continued) ensures that potential paths to the environment through containment isolation valves (including containment purge valves) are minimized. The safety analyses assume that the lower compartment and instrument room purge valves are closed at event initiation.

The DBA analysis assumes that, within 76 seconds after the accident, isolation of the containment is complete and leakage terminated except for the design leakage rate, La. The containment isolation total response time of 76 seconds includes signal delay, diesel generator startup (for loss of offsite power), and containment isolation valve stroke times.

The single failure criterion required to be imposed in the conduct of plant safety analyses was considered in the original design of the containment purge valves. Two valves in series on each purge line provide assurance that both the supply and exhaust lines could be isolated even if a single failure occurred.

The lower and incore instrument room purge valves may be unable to close in the environment following a LOCA. Therefore, each of the lower and incore instrument room purge valves is required to remain sealed closed during MODES 1, 2, 3, and 4. Although the upper containment purge isolation valves are capable of closing under accident conditions, their capability to fully seal without manual assistance has proven to be unreliable. Therefore, these valves are required to be maintained sealed closed during Modes 1, 2, 3, and 4.

The containment isolation valves satisfy Criterion 3 of 10 CFR 50.36 (Ref.

2).

LCO Containment isolation valves form a part of the containment boundary.

The containment isolation valves' safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA.

The automatic power operated isolation valves are required to have isolation times within limits and to actuate on an automatic isolation signal. The lower compartment, upper compartment, and incore instrument room purge valves must be maintained sealed closed. The valves covered by this LCO are listed along with their associated stroke times in the UFSAR (Ref. 3).

McGuire Units 1 and 2 B 3.6.3-3 Revision No.

Containment Isolation Valves B 3.6.3 BASES LCO (continued)

The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed systems are intact. These passive isolation valves/devices are those listed in Reference 3.

Purge valves with resilient seals and reactor building bypass valves must meet additional leakage rate requirements. The other containment isolation valve leakage rates are addressed by LCO 3.6.1, "Containment,"

as Type C testing.

This LCO provides assurance that the containment isolation valves and purge valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.4, "Containment Penetrations."

ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths, except for containment purge supply and exhaust valves for the lower compartment, upper compartment, and incore instrument room, to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room.

In this way, the penetration can be rapidly isolated when a need for containment isolation is indicated. For valve controls located in the control room, an operator may monitor containment isolation signal status rather than be stationed at the valve controls. Due to the size of the containment purge line penetration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls. A single purge valve in a penetration flow path may be opened to effect repairs to an inoperable valve, as allowed by SR 3.6.3.1.

McGuire Units 1 and 2 B 3.6.3-4 Revision No.

Containment Isolation Valves B 3.6.3 BASES

,ACTIONS (continued)

A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve.

In the event the containment isolation valve leakage results in exceeding the overall containment leakage rate, Note 4 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1.

A.1 and A.2 In the event one containment isolation valve in one or more penetration flow paths is inoperable except for purge valve or reactor building bypass leakage not within limit, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve inside containment with flow through the valve secured. For a penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4.

For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event McGuire Units 1 and 2 B 3.6.3-5 Revision No.

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification, through a system walkdown or computer status indication, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two containment isolation valves. For penetration flow paths with only one containment isolation valve and a closed system, Condition C provides the appropriate actions.

Required Action A.2 is modified by a Note that applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these devices once they have been verified to be in the proper position, is small.

B..1 With two containment isolation valves in one or more penetration flow paths inoperable, except for the purge valve or reactor building bypass leakage not within limit, the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak McGuire Units 1 and 2 B 3.6.3-6 Revision No.

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of their misalignment is low.

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves.

Condition A of this LCO addresses the condition of one containment isolation valve inoperable in this type of penetration flow path.

C.1 and C.2 With one or more penetration flow paths with one containment isolation valve inoperable, the inoperable valve flow path must be restored to OPERABLE status or the affected penetration flow path must be isolated.

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. A check valve may not be used to isolate the affected penetration flow path.

Required Action C.1 must be completed within the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time. The specified time period is reasonable considering the relative stability of the closed system (hence, reliability) to act as a penetration isolation boundary and the relative importance of maintaining containment integrity during MODES 1, 2, 3, and 4. In the event the affected penetration flow path is isolated in accordance with Required Action C.1, the affected penetration flow path must be verified to be isolated on a periodic basis. This periodic verification is necessary to assure leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying that each affected penetration flow path is isolated is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low.

Condition C is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with only one containment isolation valve and a closed system. The closed system must meet the requirements of Reference 5. This Note is necessary since this Condition is written to specifically address those penetration flow paths in a closed system.

McGuire Units 1 and 2 B 3.6.3-7 Revision No.

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued)

Required Action C.2 is modified by a Note that applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small.

D.1 With the reactor building bypass leakage rate not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Restoration can be accomplished by isolating the penetration(s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration(s) and the relative importance of secondary containment bypass leakage to the overall containment function.

E.1, E.2, and E.3 In the event one or more purge valves for upper and lower containment or incore instrument room in one or more penetration flow paths are not within the purge valve leakage limits, leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, or blind flange. A valve with resilient seals utilized to satisfy Required Action E.1 must have been demonstrated to meet the leakage requirements of SR 3.6.3.6. The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containment does not exist.

In accordance with Required Action E.2, this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is McGuire Units 1 and 2 B 3.6.3-8 Revision No.

Containment Isolation Valves B 3.6.3 BASES ACTIONS (continued) necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation.

Rather, it involves verification, through a system walkdown or computer status indication, that those isolation devices outside containment capable of being mispositioned are in the correct position. For the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

For the containment purge valve with resilient seal that is isolated in accordance with Required Action E.1, SR 3.6.3.6 must be performed at least once every 92 days. This assures that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge valve does not increase during the time the penetration is isolated.

F.1 and F.2 If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each containment purge supply and exhaust valve for the lower compartment, upper compartment, and incore instrument room is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. These valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A valve that is sealed closed must have motive power to the valve operator removed. This can McGuire Units 1 and 2 B 3.6.3-9 Revision No.

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued) be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term "sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 4), related to containment purge valve use during plant operations. In the event purge valve leakage requires entry into Condition E, the Surveillance permits opening one purge valve in a penetration flow path to perform repairs.

SR 3.6.3.2 Not Used SR 3.6.3.3 This SR requires verification that each containment isolation manual valve and blind flange located outside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown or computer status indication, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. The SR specifies that containment isolation valves that are open under administrative controls McGuire Units 1 and 2 B 3.6.3-10 Revision No.

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued) are not required to meet the SR during the time the valves are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing.

The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small.

SR 3.6.3.4 This SR requires verification that each containment isolation manual valve and blind flange located inside containment or annulus and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be the correct position upon locking, sealing, or securing.

This Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4, for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.

SR 3.6.3.5 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate McGuire Units 1 and 2 B 3.6.3-11 Revision No.

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)

OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses.

The isolation time is specified in the UFSAR and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option B is required to ensure OPERABILITY. The measured leakage rate for containment purge lower compartment and incore instrument room valves must be < 0.05 La when pressurized to Pa. The measured leakage rate for containment purge upper compartment valves must be < 0.01 La when pressurized to P,. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), these valves will not be placed on the maximum extended test interval, but tested on the nominal test interval in accordance with the Containment Leakage Rate Testing Program.

SR 3.6.3.7 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. The isolation signals involved are Phase A, Phase B, and Safety Injection. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

McGuire Units 1 and 2 B 3.6.3-12 Revision No.

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.3.8 This SR ensures that the combined leakage rate of all reactor building bypass leakage paths is less than or equal to the specified leakage rate.

This provides assurance that the assumptions in the safety analysis are met. The Frequency is required by the Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria.

Bypass leakage is considered part of La.

REFERENCES

1.

UFSAR, Section 15.

2.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

3.

UFSAR, Section 6.2.

4.

Generic Issue B-24.

5.

UFSAR, Section 6.2.4.2 McGuire Units 1 and 2 B 3.6.3-13 Revision No.

ATTACHMENT 3 DESCRIPTION OF PROPOSED CHANGES AN~D TECHNICAL JUSTIFICATION

SUMMARY

OF CHANGE This amendment request will revise TS 3.6.3, Containment Isolation Valves, and its associated Bases, by removing the allowance to open the upper containment purge isolation valves in the applicable modes consistent with the lower containment purge isolation valves. These valves have a history of not fully seating closed after cycling without manual assistance. Maintaining the upper containment purge isolation valves in the closed position is currently administratively controlled at McGuire in Modes 1 through 4 and assures seating characteristics are not disturbed.

Since there are no plans to upgrade these valves by modification, it is proposed to revise TS 3.6.3 and its bases accordingly. Catawba Nuclear Station TS 3.6.3 also does not allow opening the containment purge valves in Modes 1 through 4.

In addition, this amendment request will delete TS 3.3.6, Containment Purge and Exhaust Isolation Instrumentation, and its associated Bases.

This specification requires the performance of surveillance testing to demonstrate the containment purge valves will close in Modes 1 through 4 in response to containment isolation signals. The revision to TS 3.6.3 described above will maintain the containment purge valves in the sealed closed position in the modes of applicability. Therefore, there is no basis for a TS requirement to test their automatic containment isolation function. A similar change for TS 3.3.6 was submitted and approved for Catawba Nuclear Station by Amendment Nos.

196/189 dated March 20, 2002.

DESCRIPTION OF PROPOSED CHANGES TS 3.6.3, CONTAINMENT ISOLATION VALVES

.1) Note 1 under ACTIONS will be revised by adding "upper compartment" as an additional penetration restriction.

2) Surveillance Requirement (SR) 3.6.3.1 will be revised to include the upper compartment supply and exhaust purge valves from SR 3.6.3.2.

The Surveillance Requirements for the upper and lower purge valves will be identical after this change.

3) SR 3.6.3.2 will be deleted since this SR for the upper compartment purge valves will become identical to SR 3.6.3.1.

1

4) Replace "instrument room" with "incore instrument room" in ACTIONS, SR 3.6.3.1, and SR 3.6.3.6 to be consistent with the UFSAR and Design Basis Documents.

TS BASES 3.6.3, CONTAINMENT ISOLATION VALVES

1) Add a sentence to the Background section stating that the Containment Purge System is only used during Mode 5, Mode 6, and No Mode.

Replace "noble gases" with "airborne radioactivity" since it's a more complete term.

2) Delete sentences from the Background section that state the upper containment purge can operate inModes 1-4 with no more than one pair of valves open.

Delete sentence stating that the lower compartment purge valves are only used during refueling operations.

3) In the Applicable Safety Analysis section, delete the sentences that state the upper purge valves may be opened for ALARA considerations.

Add sentences stating that the upper purge valves may not fully seal without manual assistance and are therefore maintained sealed closed in Modes 1-4.

4) In the LCO section, add "upper compartment" to sentence that states the purges valves must be maintained sealed closed.

5) In the Actions section, add "upper compartment" to sentence that excludes the purge valves from being intermittently un-isolated under administrative controls.

6) Revise the Bases for SR 3.6.3.1 to include the upper compartment supply and exhaust purge valves from the Bases for SR 3.6.3.2.

The Surveillance Requirements for the upper and lower purge valves will be identical after this change.

Delete the sentence regarding the purge valves inability to close in time during a LOCA since it is not the primary reason for maintaining the purge valves closed in Modes 1 through 4.

7) The Bases for SR 3.6.3.2 will be deleted since the requirements will become identical to the Bases for SR 3.6.3.1.

8) Replace "instrument room" with "incore instrument room" in the Bases to be consistent with the UFSAR and Design Basis Documents.

2

TS AND BASES 3.3.6, CONTAINMENT PURGE AND EXHAUST ISOLATION INSTRUMENTATION

1) This TS and Bases will be deleted.

The TS and Bases Table of Contents will be revised accordingly.

TECHNICAL JUSTIFICATION The Containment Purge System operates to supply outside air into containment for ventilation and cooling or heating and may also be used to reduce the concentration of airborne radioactivity within containment.

There are five purge air supply and four purge air exhaust penetrations through containment.

Two normally closed isolation valves at each penetration provide containment isolation.

The containment purge isolation valves at McGuire were determined to be unreliable with regard to maintaining leak tightness after cycling several years ago.

Because of this, a license amendment request was submitted and approved exempting these valves from quarterly testing contingent upon administratively maintaining these valves closed.

Leak rate testing per SR 3.6.3.6 is performed near the end of each refueling outage when the valves are sealed closed.

Maintaining the containment purge isolation valves in the sealed closed position is currently administratively controlled in Modes 1 through 4 and assures seating characteristics are not disturbed.

There are no plans to upgrade these valves by modification.

As a result, there is no reason to maintain the allowance for opening one pair of upper containment purge isolation valves in Modes 1 through 4 as allowed by TS 3.6.3.

This is considered to be a conservative Technical Specification change.

Catawba also treats their containment purge isolation valves in the same manner and has removed the allowance for opening from their TS 3.6.3.

Since these power operated containment isolation valves are sealed closed, they are no longer considered to be automatic isolation valves as defined in ANSI N271-1976, "Containment Isolation Provisions for Fluid Systems."

This ANSI standard was endorsed by Regulatory Guide 1.141 of same title.

3

TECHNICAL JUSTIFICATION (continued)

The McGuire safety analysis assumes that the containment purge isolation valves are closed at the initiation of an accident to minimize releases of radioactivity.

To assure this, these valves receive an automatic safety injection (SI) signal through the containment isolation Phase A function which would close the purge valves if containment purging was in progress in Modes 1 through 4.

The isolation instrumentation that performs this function is governed by TS 3.3.6 and satisfies Criterion 3 of 10 CFR 50.36.

The re-classification of all the Purge System containment isolation valves from automatic to sealed closed maintains the valves in their design basis position prior to initiation of any design basis accident.

The provision to allow purging containment in Modes 1 through 4 will no longer be allowed.

The purge valves are leak rate tested once they are placed in the sealed closed position then verified sealed closed every 31 days.

Therefore, Criterion 3 of 10 CFR 50.36 no longer applies to the Containment Purge System Isolation Instrumentation System.

In conclusion, the LCO and Surveillance Requirements of TS 3.3.6, which tests the containment isolation instrumentation automatic actuation logic and relays, is no longer required so TS 3.3.6 may be deleted.

Catawba has also used this justification to delete this system from their TS 3.3.6 (see Catawba Amendment Nos. 196/189 dated March 20, 2002).

4

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION As required by 10 CFR 50.91(a) (1),

this analysis is provided to demonstrate this Duke Energy License Amendment Request (LAR) does not involve a significant hazards consideration.

This LAR will revise Technical Specification (TS) 3.6.3, Containment Isolation Valves, by removing the allowance to open the upper containment purge isolation valves in the applicable modes consistent with the lower containment purge isolation valves.

Maintaining the upper containment purge isolation valves in the closed position is currently administratively controlled in Modes 1 through 4 at McGuire Nuclear Station.

These valves have a history of not fully seating closed after cycling without manual assistance.

Since there are no plans to upgrade these valves by modification, it is proposed to revise TS 3.6.3 and its bases accordingly.

Catawba Nuclear Station TS 3.6.3 also does not allow opening the containment purge valves in Modes 1 through 4.

In addition, this LAR will delete TS 3.3.6, Containment Purge and Exhaust Isolation Instrumentation.

The revision to TS 3.6.3 described above will maintain the containment purge isolation valves in the sealed closed position in the modes of applicability.

Therefore, there is no basis for a TS requirement to test their automatic containment isolation function.

A similar change was submitted and approved for Catawba Nuclear Station by Amendment Nos. 196/189 dated March 20, 2002.

Conformance of this LAR to the standards for a determination of no significant hazards, as defined in 10 CFR 50.92, is shown in the following:

1. Does this LAR involve a significant increase in the probability or consequences of an accident previously evaluated ?

No.

The Containment Purge System is not capable of initiating any accident by itself so there will be no increase in the probability of an accident.

Since these containment isolation valves will be maintained in the sealed closed position, there can be no increase in the consequences of an accident.

The design and operation of the Containment Purge System is not being modified by this LAR.

Therefore, approval and implementation of this LAR will have no effect on accident probabilities or consequences.

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION (continued)

2.

Does this LAR create the possibility of a new or different kind of accident from any accident previously evaluated ?

No.

This LAR does not involve any physical changes to the Containment Purge System so no new or different accident causal mechanisms will be generated.

Also, no changes are being made to the way in which the Containment Purge System is operated.

Some surveillance tests will no longer be performed but these tests are no longer necessary since the affected components remain in their safe, design basis position.

Consequently, plant accident analyses will not be affected by this LAR.

3.

Does this LAR involve a significant reduction in a margin of safety ?

No.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following accident conditions.

These barriers include the fuel cladding, the reactor coolant system, and the containment system.

The performance of these barriers will not be affected by the proposed changes.

The containment isolation valves in the Containment Purge System will continue to perform their design basis function after this LAR is implemented.

CONCLUSION Based on the preceding discussion, it can be concluded that this LAR does not involve a significant hazards consideration as defined in 10 CFR 50.92.

ATTACHMENT 5 ENVIROMENTAL ASSESSMENT / IMPACT STATEMENT This License Amendment Request (LAR) has been reviewed against the criteria of 10 CFR 51.22 for environmental considerations.

This LAR does not involve a significant hazards consideration, increase the types and amounts of effluents that may be released offsite, or result in the increase of individual or cumulative occupational radiation exposures.

Therefore, this LAR to the McGuire Technical Specifications meets the criteria provided by 10 CFR 51.22(c) (9) for categorical exclusion from the requirement for an Environmental Impact Statement.

ML062200466

Text

Subject:

6.3 BACKGROUND

SUMMARY

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